Responses to Comments Received During Significant Action Process for Proposed Transfer by Sale of Unused Development Rights from Piers 59, 60, and 61 and the Associated Headhouse in the Chelsea Section of Hudson River Park A. Overview On February 13, 2018, pursuant to the Significant Action process mandated by the Hudson River Park Act (as amended, the “Act”), the Hudson River Park Trust (“HRPT”) issued a public notice (the “Notice”) inviting public review and comment regarding the proposed transfer by sale of (1) 123,437.5 square feet of unused development rights from Piers 59, 60 and 61 and the associated headhouse in the Chelsea section of Hudson River Park (the “Granting Site”) to DD West 29th LLC for its construction of a new building at 601 West 29th Street (“project site A”) and (2) 29,625 square feet, or in the alternate, 34,562.5 square feet of unused development rights from the Granting Site to West 30th Street LLC for its development of a new building at 606 West 30th Street, or in the alternative 604 to 606 West 30th Street (“project site B”) (together, the “Air Rights Transfer”). In tandem with HRPT’s Significant Action process, a number of actions pertaining to the proposed Block 675 East Project were separately reviewed through New York City’s Uniform Land Use Review Procedure (“ULURP”), City Environmental Quality Review (“CEQR”), and the State Environmental Quality Review Act and its implementing regulations in 6 NYCRR Part 617 (“SEQRA”). The New York City Department of City Planning (“DCP”), acting on behalf of the City Planning Commission (“CPC”), was designated the lead agency for the required environmental review, and the Trust was named as an involved agency. On April 27, 2018, the DCP issued a Final Environmental Impact Statement (“FEIS”) for the Block 675 East Project. On June 25, 2018, DCP determined, pursuant to Technical Memorandum 002, that certain modifications related to the reduction in height of the tallest residential structure and additional commitments related to child care and open space impacts do not have the potential to result in new or different significant adverse environmental impacts than those disclosed in the FEIS. In accordance with the Act’s requirements, HRPT’s Notice was published in the following places: HRPT’s website; the City Record; the New York State Reporter; the New York Post; and Chelsea Now. Additionally, as required by the Act, the Notice was circulated to Manhattan Community Boards 1, 2 and 4; to the CPC; to the Hudson River Park Advisory Council; to local elected officials representing communities neighboring the Park; and to other interested community leaders, neighbors, partners and organizations. HRPT made a variety of documents related to the proposed Air Rights Transfer available on its website. As required under the Significant Action process, HRPT held a public hearing on March 14, 2018 at 10:00 am at Department of City Planning, 120 Broadway, Concourse Level, New York, New York. The hearing was held in conjunction with the CPC’s public hearing pursuant to ULURP and SEQRA. 1 HRPT’s comment period remained open until April 16, 2018. In addition to the comments filed with CPC in writing and in person during the March 14 public hearing on the Draft Environmental Impact Statement (“DEIS”), HRPT received two written comments in response to its Significant Action Notice. All comments received at the hearing and in writing to CPC are part of HRPT’s official record. HRPT staff worked jointly with DCP to respond to relevant comments that were received on the DEIS, and the FEIS Chapter 27 included such responses. The responses to comments below on the Significant Action Notice include all the responses to comments contained in Chapter 27 of the FEIS. HRPT has also provided additional responses to Comments Nos. 11, 26, 32, and 33 that specifically relate to HRPT’s Significant Action Notice and were not included in the FEIS Chapter 27 Response to Comments. B. LIST OF ORGANIZATIONS AND INDIVIDUALS WHO COMMENTED ON THE DEIS ELECTED OFFICIALS 1. Gale A. Brewer, President, Borough of Manhattan, letter dated March 7, 2018 (Brewer_001) and oral comments received March 14, 2018 (Brewer_018) COMMUNITY BOARD 2. Manhattan Community Board 4 (“CB4”)—letters dated February 5, 2018 (CB4_002, CB4_003); Betty Mackintosh, Co-Chair, Chelsea Land Use Committee, written and oral comments received March 14, 2018 (CB4_Mackintosh_005, CB4_Mackintosh_012); Lornell Kern, Co-Chair, Waterfront, Parks & Environment Committee, oral comments received March 14, 2018 (CB4_Kern_014); Paul Devlin, Member, Chelsea Land Use Committee, oral comments received March 14, 2018 (CB4_Devlin_013); Joe Restuccia, Member, oral comments received March 14, 2018 (CB4_Restuccia_015) ORGANIZATIONS 3. Clean Air Campaign—email dated March 8, 2018 (CAC_007); Marcy Benstock, Executive Director, written and oral comments received March 14, 2018 (CAC_006, CAC_023) 4. Friends of Earth—Bunny Gabel, written and oral comments received March 14, 2018 (Gable_FoE_008, Gabel_FoE_022) 5. Hudson River Park Friends—Tony Simone, Director of External Affairs, oral comments received March 14, 2018 (HRPF_019) 6. Hudson River Park Trust, written and oral comments received March 14, 2018 (HRPT_010, HRPT_016, HRPT_017, HRPT_024) 7. Service Employees International Union, Local 32B—Panos Kourtis, oral comments received March 14, 2018 (32BJ SEIU) GENERAL PUBLIC 8. Phil O’Brien, Publisher, West 42nd Street Magazine, oral comments received March 14, 2018 (O’Brien_020) 9. Melvyn Stevens, written and oral comments received March 14, 2018 (Stevens_009, Stevens_011) 2 C. LIST OF INDIVIDUALS FILING COMMENTS DIRECTLY TO HRPT DURING THE SIGNIFICANT ACTION PROCESS 10. Phyllis C. Waisman, written comments dated April 2, 2018 (Waisman) 11. Anthony Borelli, written comments dated March 27, 2018 (Borelli) D. COMMENTS AND RESPONSES PROJECT DESCRIPTION PROJECT SITE A Height and Bulk Comment 1: The height of the proposed development on project site A will play a role in determining the context and character of surrounding developments. CB4 recommended that building bulk regulations for Block 675 should be guided by the 450-foot height of the Special West Chelsea District Subarea A. CPC’s 2017 Planning Framework for Block 675 recommended C6 districts with an “appropriate massing response to a transitioning context.” However, given the addition of 2 FAR from the Park to the 10 FAR allowed in the C6-4X district, a 20 percent increase, CB4 revised their recommendation to allow for a corresponding 20 percent increase in maximum height, from 450 feet to about 550 feet. This would also represent a step down from the 642-foot heights of the proposed residential buildings on the north side of West 30th Street at Hudson Yards Sites 6A and 6B. CB4’s recommendation of 550 feet for project site A is reasonable, while the proposed height of 660 feet is excessive. CB4’s long- standing preference for lower heights in the mid-blocks, as well as their agreement with the decrease in height moving westward towards the Hudson River, means that the proposed building on project site A should be the tallest building on the block. (Brewer_001, Brewer_018, CB4_002, CB4_003, CB4_Restuccia_015) The design of the proposed project, with its tri-part division of gallery level, mid- rise, and tower is appreciated. However, the bulk should be distributed across the site to lower the height, especially considering that the applicant is asking for additional height, setback, and tower coverage waivers. (Brewer_001, Brewer_018) Response: The overall bulk of the building proposed for project site A has been concentrated on the eastern end of the site, situating it closer to the subway station (7 train) entrance and avoiding the floodplain to the greatest degree possible. It has been designed with a site-specific massing that addresses the transition between Hudson Yards to the north and West Chelsea to the south, while avoiding overly large masses and minimizing shadows on the High Line. To realize this transition, the massing incorporates three distinct volumes, each responding to the scale of the adjacent context. The base of the building consists of an 85-foot-high street wall that reflects the West Chelsea mid-blocks. The 399-foot-high “shoulder” reflects the scale of the taller West Chelsea apartment houses. The east-west dimension of the “shoulder” is limited to approximately 175 feet, a generally agreed maximum length of a “slab.” It is worth noting that redistribution of bulk (in an effort to reduce the tower height) would cause this dimension to grow, creating an overly 3 long building form and increasing shadows on the High Line. The 660-foot-high tower portion reflects the transition from the taller Hudson Yards towers to the north. The tower is oriented north-south, minimizing its shadows on the High Line and creating a slender profile on the skyline as seen from West Chelsea. Regarding the overall height of the building proposed for project site A and its appropriateness as a transition between Hudson Yards and West Chelsea, it is worth noting that the height of the tower planned immediately to north is 810 feet. 15 Hudson Yards, diagonally opposite project site A, recently topped out at approximately 920 feet. The proposed height of 660 feet results in a step-down of between 150 to 260 feet from these buildings, a significant and noticeable dimension.1 Comment 2: It is recommended that the City relocate the West 23rd Street EMS facility to an enclosed space in the proposed project. Given the high profile of this area, with Hudson Yards, the Hudson Tunnel, and numerous other major developments nearby, the public safety need must be properly met. (Brewer_001, CB4_002) The committed space from the Douglaston team should be delineated as a permanent City/community facility, not retail or parking. (CB4_Devlin_013) Response: The design of the proposed project allows for inclusion of the EMS Facility in an enclosed space.